HART v. COMMISSIONER

Docket No. 457-80.

46 T.C.M. 530 (1983)

T.C. Memo. 1983-364

David E. Hart and Barbara A. Hart v. Commissioner.

United States Tax Court.

Filed June 20, 1983.


Attorney(s) appearing for the Case

Randall G. Dick and Suzanne Cutts Ritchie, 220 Jackson St., San Francisco, Calif., for the petitioners. Michael R. Morris, for the respondent.


Memorandum Findings of Fact and Opinion

RAUM, Judge:

The Commissioner determined a $2,118,576 deficiency in petitioners' Federal income tax for 1974. After concessions, the amount involved has been substantially reduced. The issue remaining for decision is whether a $1,000,000 "loan" made by a corporation in 1974 to a trust of which petitioners and their children were the beneficiaries, which "loan" was made pursuant...

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